DHS Proposes Changes to Biometrics Collection and Use in U.S. Immigration System

Strategic Insights -

The U.S. Department of Homeland Security's Citizenship and Immigration Services has proposed a significant overhaul of its biometrics collection and use policies, affecting individuals of all ages who file or are associated with immigration benefit requests. The proposed rule seeks to mandate biometrics submission for all individuals, with exemptions only for certain cases. This change aims to enhance identity management, deter fraud, and improve the consistency of vetting processes by transitioning from a biographic data-based system to a biometric-based system for identity verification.

Key Takeaways:

  • The proposed rule would require the submission of biometrics by any individual, regardless of age, who files or is associated with an immigration benefit request, unless exempted.
  • The proposed rule would expand the authority for collecting biometrics upon alien arrest and provide a clear definition of the term "biometrics" for its application throughout the immigration system.
  • The change would establish an "extraordinary circumstances" standard to excuse a failure to appear at a biometric services appointment.
  • The proposal modifies how certain Violence Against Women Act (VAWA) self-petitioners and T nonimmigrant status applicants are to demonstrate good moral character.
  • The overall goal is to enhance identity management, deter fraud, and improve the consistency of vetting processes.
  • The shift towards a biometric-based system aims to reduce reliance on biographic data, which may be inconsistent or easily altered, by ensuring that immigration records accurately pertain to one individual.

Statistics:

  • The proposed rule seeks to require the submission of biometrics by an estimated 3.5 million individuals in FY 2026 (Source: Table 1--Summary of Provisions and Impacts).
  • The total range of costs for submitting DNA evidence is estimated at $1.7 million (Source: Table 15--DNA Tests and Associated Costs).
  • The discounted total monetized costs over a 10-year period are estimated at $288.7 million (Source: Table 18--Discounted Total Monetized Costs Over a 10-Year Period of Analysis).
  • Between FY 2020 and FY 2024, an estimated 22,500 DNA tests were submitted at International Facilities for Form I-130, Form I-730, the Haitian Family Reunification Parole Program, the Cuban Family Reunification Parole Program, and the Filipino WWII Veterans Parole Program (Source: Table 4--DNA Test Submissions at International Facilities).

Sources:

  • DHS Docket No. USCIS-2025-0205 Collection and Use of Biometrics by U.S. Citizenship and Immigration Services (Federal Register, 2025, 19747)
  • Jaymar Talang, Targeted News Service (Federal Register, 2025, 19747)
  • Table 1--Summary of Provisions and Impacts (Federal Register, 2025, 19747)
  • Table 15--DNA Tests and Associated Costs (Federal Register, 2025, 19747)
  • Table 18--Discounted Total Monetized Costs Over a 10-Year Period of Analysis (Federal Register, 2025, 19747)
  • Table 4--DNA Test Submissions at International Facilities (Federal Register, 2025, 19747)